Testimony of Pam Hardwicke 

Clean Air Task Force 

May 24, 2012 

CLE :F') 

TASK FORCE 

On behalf of the Clean Air Task Force, I would like to offer comments on U.S. EPA's 

proposed lll(b) rule that will establish C02 emissions limits on new fossil power 

plants. 

The Clean Air Task Force is an international nonprofit environmental organization 

headquartered in Boston, Massachusetts that operates throughout the United States 

and China. CATF focuses on the key atmospheric air pollution issues of the 21 st 

century: greenhouse gas emissions that drive climate change, and particulate matter 

that linked to premature death and disease. 

Our staff works extensively with companies in both the US and China that develop 

advanced low-carbon technologies, including carbon capture and storage (CCS). 

Carbon capture and storage is an available technology that U.S. EPA can and should 

rely upon in establishing C02 emission limits for new fossil fuel electrical generating 

units (EGU). 

In Kemper County Mississippi, Plant Radcliffe is a new 582 MW coal power plant 

that is under construction. When it opens in 20 J 4, the plant will capture 65% of its 

18 Tremont St., Suite 530 I Boston, MA 021081 www.catf.us 1617.624.0234 
C02 and sequester them deep underground. The C02 emissions from this plant are 

estimated at 550 lb/MWWh (gross). 

In Odessa Texas, the Texas Clean Energy Project (TCEP) is expected to break ground 

later this year. The 400 MW project will turn coal into base load power, fertilizer and 

produce C02 that will be sequestered deep underground. TCEP will capture over 

90% of the C02 it would otherwise emit. The emission rate for this plant when it 

goes into operation in 2015 will be 228 lb/MWWh (gross). 

Other projects that use CCS are advancing as well. EPA is not limited to looking at 

EGU applications. Earlier this month, the Indiana Department of Environmental 

Management (IDEM) fil ed an air permit with U.S. EPA region 5 for the Indiana 

Gasification LLC project in Rockport. While this project is not intended to produce 

significant electricity generation, it will tum coal into natural gas and the permit 

requires CCS. The plant will capture at least 80% of the C02 that would otherwise 

be emitted. The liquefied C02 from the plant will be sequestered deep underground 

and thereby permanently isolated from the atmosphere. 

While these projects are new, it is important to emphasize that the components of 

CCS have been demonstrated and used successfully both in this country and abroad 

for many, many years. 
o In Texas alone, over 1 billion tons of carbon dioxide already has been 

sequestered underground. EOR is an important technology because 

revenue from the sale of C02 helps pay for CCS costs. The capacity of 

EOR to handle C02 emissions is large in the United States. A new DOE 

study notes that 67 billion barrels of oil are economically recoverable at 

an oil price of $85 per barrel. This would require the purchase of 20 

billion metric tons of C02 at a projected price of $40/ton. This is 

equivalent to 30 years of C02 emissions from 93 GW of coal plants.1 

o In evaluating BSER, EPA is not limited only to domestic applications. In 

Norway, the Sleipner C02 injection operation in the North Sea has 

isolated 8-9 million tons of C02 in a saline formation since 1996 without 

evidence ofleakage.z 

o Moreover, the US already has over 4,000 miles of C02 pipelines in 

operation. C02 pipelines carry C02 from natural reservoirs as well as 

industrial sources to EOR sites. The expansion ofthis network to meet 

1 NETL, Improving Domestic Energy Security and Lowering C02 Emissions with 

Next Generation C02-Enhanced Oil Recovery (C02-EOR), June 2011, page 1. 2 Sleipner Fact Sheet: Carbon Dioxide Capture and Storage Project, available at 

http://sequestration.mit.edu/tools/projects/sleipner.html 
future C02 transportation needs presents no new technical or regulatory 

uncertainties. 

o In addition to the plants described above, carbon capture technology is 

operating in a variety of settings and fuels in the United States and across 

the world. For example, in the U.S., Plant Barry near Mobile, Alabama is 

capturing C02 using post-combustion capture technology, and the Dakota 

Gasification Plant in North Dakota has been using pre-combustion 

capture technology to capture C02 and send it via pipelines to oil fields in 

Canada, where it is sequestered via enhanced oil recovery options. In 

China, the Shidongkou post-combustion CCS facility has been removing 

over 120,000 tons of C02 from a coal-fired power plant outside Shanghai 

since 2010. 

I appreciate this opportunity to comment at this hearing. CATF intends to file more 

detailed materials into the record as part of our written comments due by June 24, 

2012. 

Thank you, 

Pam